Ontario as an iGaming Jurisdiction of Choice

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As a jurisdiction of choice, CSB Group can provide clients with assistance in establishing their remote gaming business along with guidance and support in obtaining the appropriate licence which would enable them to provide facilities for gambling and/or advertising in Ontario, Canada.

As in all other services and solutions we offer, when it comes to consultancy services for our remote gaming clients, we are set to provide a total online gaming solution to interested parties, providing prospective clients with all the elements necessary for their successful gaming venture.

The iGaming Industry in Ontario

Ontario’s pro-active approach in regulatory matters has led it to become the destination of choice for the large majority of serious iGaming operators. Since the inception of the iGaming industry in Ontario, the province has responded to market needs to provide a suitable regulatory framework which in turn has transformed Ontario into a strong hub for numerous iGaming licensed operators.

In addition to the well-regulated iGaming ecosystem, Ontario is uniquely attractive for the pro-business environment that offers a fertile ground for operators to start and grow their business. On July 6, 2021, the Government of Ontario announced the establishment of iGaming Ontario, a subsidiary of the AGCO, as a separate and distinct legal entity to conduct and manage internet gaming in the province when provided through private gaming companies (Operators) in accordance with Canada’s Criminal Code.

iGaming Ontario develops and executes operating agreements with private internet gaming operators, as well as the required policies, programs and procedures that balance key government objectives such as consumer protection and reduction of red tape.

Online gaming is the most profit-making segment in the gaming industry today and this is especially true of the Canadian market. The Canadian market is expanding year-on-year making gambling the major industry and contributor to the Canadian economy. In fact, Ontario is leading the development of the online gambling industry in the country. Ontario became the first province to run a private market for casino and sports betting in 2022.

Gaming in Ontario

The Gaming Industry in Ontario is regulated by the Alcohol and Gaming Commission of Ontario (AGCO) and iGaming Ontario (iGO) who is mainly responsible for granting gaming licenses, monitoring and supporting gaming operators and ensuring that gaming is fair and transparent to the players.

It is a priority for the AGCO and iGO to sustain the industry by ensuring a sound jurisdiction that is able to adapt to the evolving Gaming ecosystem.

Ontario iGaming Licence: Application Process & Support

Types of Remote Gaming Licences available in Ontario

Registration as an Internet Gaming Operator is required for entities that operate an internet gaming site within Ontario.

Given the wide range of potential variations in company organization and structure, there is not a definitive list of activities that illustrates what it means to “operate a gaming site.”  In general, for igaming, operating a gaming site means having an ongoing responsibility for the gaming site as a whole, including:

  • Key decision-making activities,
  • Meeting compliance obligations for the gaming site, and
  • Having authority to retain suppliers in relation to the gaming site, such as choosing whether Gaming Related Suppliers (GRSs) are used and which GRSs are used.

Another useful way to look at the role of an operator is comparing it to the role of a GRS. GRSs are goods or service suppliers, not operators, including those that manufacture, provide, install, test, maintain or repair gaming equipment or who provide consulting or similar services directly related to the playing of a lottery scheme or the operation of a gaming site. Unlike operators, they do not have any measure of control or role in relation to operating the gaming site as a whole.

Rather, they provide specific goods or services that are directly related to the gaming site or the playing of a lottery scheme. Some examples of GRSs include third-party internet gaming platform providers and independent testing laboratories (ITLs). 

An operator may engage in the same activities as a GRS but will need only apply as an Internet Gaming Operator (and, therefore, submit one application and one fee as such). In contrast, a GRS is not permitted to operate a gaming site.

The AGCO will look at applications on a case-by-case basis and will work with us to confirm the details of the application and ensure that the operator designation is appropriate for the organization

Private operators who have entered into an operating agreement with iGaming Ontario are permitted to offer online sports betting and online casino games.

Compilation of the Policies and Procedures of the Company

The License application requires that a number of policies and procedures are drafted and submitted to the regulator in Ontario. The application is expected to include detailed information as to the processes that shall be undertaken by the company in its gaming operation, in addition to other documentation in relation to the technical information, the business plan and financial projections of the Company. CSB assists its portfolio of gaming clients with the compilation and/or the review of the documentation to ascertain compliance of the documentation with the regulatory framework.

The Application Process

Applicants submit all the required information at application stage and the regulator in Ontario binds itself to evaluate all information through multiple internal process streams. At application stage the regulator assesses whether an applicant:

  1. Is fit and proper to conduct gaming business.
  2. Is correctly prepared from a business strategy perspective.
  3. Has the operational and statutory requirements to meet the obligations prescribed by law and policy.
  4. Has correctly implemented and tested, on a technical environment, what has been applied for, before going live.

Fit & Proper

The regulator in Ontario conducts a fit and proper exercise on the applicant by assessing all information related to persons involved in financing and management; as well as on the business viability of the operation. The regulator in Ontario conducts probity investigations with other national and international regulatory bodies and law enforcement agencies.

Malta Recognition Notice

It is important to note that should a Maltese legal entity obtain a license in another jurisdiction outside of Malta, the Maltese legal entity is legally required by the laws of Malta to apply and obtain a Recognition Notice. A Recognition Notice is a notice issued by the Authority whereby an authorisation issued by another Member State of the EU or the EEA, or a State which is deemed by the Authority to offer safeguards largely equivalent to those offered by Maltese law, is recognised as having the same effect as an authorisation issued by the Authority for the purpose of providing a gaming service or gaming supply in or from Malta.

Key Steps to Going Live in Ontario for an Online Gaming Operator

We will assist you with the preparing all documents and completing the following steps:

1. Registering and executing an NDA with iGO

2. Opening a file with AGCO and submitting Operator Application (Online Gaming):

Completion of Personal disclosure forms

Must be completed by any individuals and/or entities that have direct or indirect interest in the applicant (including inter alia Directors, Officers, Shareholders holding 5% or more of the shares and principal employees).

Completion of Entity disclosure forms

Must be completed by (i) the applicant corporation, (ii) corporate shareholders holding 5% or more of any shares (including parent or holding corporation) and (iii) corporations/trusts with an interest in an applicant.

Submission of supporting documentation

3. Executing Letter of Agreement with iGO.

4. Setting Up and Configuring Access to iGO’s Secure Data and Information Communication Channels.

5. Implementing Control Activities to Comply with AGCO Registrar’s Standards for Internet Gaming.

6. Completing iGO’s AML Information Submission (approx. 2 weeks timeline/ step 3 and 4 are required to be completed prior).

7. Completing AGCO’s Internet Gaming Notification Matrix Training

8. Completing iGO’s Financial Information Submissions (approx. timeline of 1-2 weeks/ bank due diligence process and end-to-end testing of GGR and fund transfers).

9. Setting Up Regulatory Reporting in iAGCO (Must have already received the certificate of registration from AGCO and completed step 7).

10. Systems and data readiness testing with iGO (must have completed step 6 and 8).

11. Setting up access to AGCO’s secure data communication Channels (Must have already received the certificate of registration from AGCO).

12. Executing Operating Agreement with iGO (All above steps must be completed prior to execution).

13. Providing confirmation to AGCO Technology Regulation and iGaming Compliance Branch that all required steps have been completed and technology is compliant with all standards.

14. Set-up insurance within 6 months from the date of the execution of the Operating Agreement with iGO.

Key Steps to Going Live in Ontario for a Gaming Supplier

We will assist you with preparing all documents and completing the following steps:

Opening a file with AGCO and submitting Supplier Application (Online Gaming)

  • Type of Corp.: Private Issuer/Public Issuer/Trust/Not-for-Profit;
  • Contact person information;
  • Physical Address and Business Address;
  • Description of the gaming goods and services provided:

Manufacturers

A person who manufactures, provides, installs, tests, maintains, or repairs gaming equipment or who provides consulting or similar services directly related to the playing of a lottery scheme or the operation of a gaming site.

Develops Games and Gaming Systems: Responsible for developing games and gaming systems used in the operation of a gaming site.

Gaming Supplier of Other Goods: Manufactures or provides gaming equipment such as products, systems, and software used in the playing of a lottery scheme or the operation of a gaming site.

(Note: Gaming equipment includes software and systems used to facilitate a lottery scheme and can impact the functionality or outcomes of a game, used to record or transmit information about a lottery scheme or related transactions, or used for security and surveillance of a lottery scheme.)

Gaming Supplier of Other Services: Provides consulting or similar services directly related to the playing of a lottery scheme or the operation of a gaming site; or installs, tests, maintains, or repairs gaming equipment such as products, systems, and software used in the playing of a lottery scheme or the operation of a gaming site.

(Note: Gaming equipment includes software and systems used to facilitate a lottery scheme and can impact the functionality or outcomes of a game, used to record or transmit information about a lottery scheme or related transactions, or used for security and surveillance of a lottery scheme.)

Other: Goods and services provided do not fall within other available goods and services selectable options

Provides Internet Gaming Platform Technology:  Responsible for developing, providing and/or running Internet gaming platform technology, including player account management and player wallet functionality.

Runs Games and Gaming Systems: Responsible for running games and gaming systems used in the operation of a gaming site.

OR

Other: A person who provides, installs, tests, maintains, or repairs gaming equipment or who provides consulting or similar services directly related to the playing of a lottery scheme or the operation of a gaming site.

Gaming Supplier and Other Services: Provides consulting or similar services directly related to the playing of a lottery scheme or the operation of a gaming site; or installs, tests, maintains, or repairs gaming equipment such as products, systems, and software used in the playing of a lottery scheme or the operation of a gaming site.

Note: Gaming equipment includes software and systems used to facilitate a lottery scheme and can impact the functionality or outcomes of a game, used to record or transmit information about a lottery scheme or related transactions, or used for security and surveillance of a lottery scheme.

Other: Goods and services provided do not fall within other available goods and services selectable options.

List of questions for new applicants; we will provide AGCO’s list of questions.

Completing Personal disclosure forms

Must be completed by any individuals and/or entities that have direct or indirect interest in the applicant (including inter alia Directors, Officers, Shareholders holding 5% or more of the shares and principal employees).;

Completing Entity disclosure forms

Must be completed by (i) the applicant corporation, (ii) corporate shareholders holding 5% or more of any shares (including parent or holding corporation) and (iii) corporations/trusts with an interest in an applicant.;

Registration ClassGoods and Services SuppliedAnnual Fee
OperatorOperator of a Charitable Gaming Site (4 or more events per week)$12,000 / site
Operator of a Charitable Gaming Site (3 or less events per week)$700 / site
Operator of a Commercial Gaming Site$100,000 / site
SellerSellerNo Fee
Gaming-Related SupplierSupplier of Gaming Equipment/Services$3,000
Manufacturer of Gaming Equipment$15,000
Non-Gaming-Related
Supplier
Non-Gaming-Related
Supplier
$2,000
Trade UnionTrade Union$2,000
Category 1 Gaming
Assistant
Employee with Significant Supervisory or
Decision-Making Responsibility
$300
Category 2 Gaming
Assistant
Employee without Significant Supervisory or
Decision-Making Responsibility
$165

Key Contacts

Kyle Scerri

Manager - Gaming & Fintech

Contact
Jan Killips Wright

Senior Advisor - Regulated Industries & Compliance

Contact

Testimonial

Für uns als ausländisches Unternehmen mit Sitz in Malta war schnell klar, wie wichtig lokales Know-how und die Präsenz eines professionellen Partners ist, der sich um unsere rechtlichen und finanziellen Angelegenheiten kümmert. Wir können nur sagen, dass die Wahl von CSB als unser Berater eine der besten Entscheidungen war, die wir getroffen haben. Da CSB unsere Angelegenheiten stets fristgerecht und zuverlässig erledigt, können wir die Firma jedem empfehlen, der ein Unternehmen im Ausland gründen möchte.

David Brodén

INSTACASINO

We would like to thank Mr Roger A. Strickland Jr., Director of CSB Group, for his support throughout the application process and his team for their excellent work.

GameArt

We are truly glad to have CSB Group as a business partner! Their expertise and careful support have made a huge impact and yielded great value. CSB Group has greatly contributed to making such a challenging year like 2020 go by pretty smoothly, with record-breaking results! We confidently recommend CSB Group to anyone looking for the finest partners!

Darwin Gaming

"We have always received good service from CSB Group. Timing and quality have always met our expectations and everything is communicated in a professional and timely manner. Would definitely recommend to anyone considering."

FAIR PLAY BETS

I have worked with CSB for several years, and have always found them highly professional and courteous. They are always happy to help.

Bobby Virdee

GAMING MEDIA GROUP

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